IR 05000440/2020403

Security Baseline Inspection Report 05000440/2020403

ML20336A174
Person / Time
Site:	Perry
Issue date:	12/01/2020
From:	Steven Orth Plant Support Branch II
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2020403
Download: ML20336A174 (8)

Text

December 1, 2020

SUBJECT:

PERRY NUCLEAR POWER PLANT - SECURITY BASELINE INSPECTION REPORT 05000440/2020403

Dear Mr. Penfield:

On October 22, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant and discussed the results of this inspection with Mr. Frank Payne and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Docket No. 05000440 License No. NPF-58

Enclosure:

As stated

Inspection Report

Docket Number: 05000440 License Number: NPF-58 Report Number: 05000440/2020403 Enterprise Identifier: I-2020-403-0032 Licensee: Energy Harbor Nuclear Corp.

Facility: Perry Nuclear Power Plant Location: Perry, OH Inspection Dates: October 5, 2020 to October 22, 2020 Inspectors: N. Egan, Senior Physical Security Inspector J. Kutlesa, Physical Security Inspector Approved By: Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at Perry Nuclear Power Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Unless otherwise noted, baseline security inspections were conducted in accordance with the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2201, Security Inspection Program for Commercial Nuclear Power Reactors. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. Publicly available IPs are located at:

http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), regional inspectors were directed to begin telework. The inspection documented below was determined that the objectives and requirements stated in the IP could, in part, be performed remotely.

71130.02 - Access Control

The inspectors evaluated the access control program through completion of the following

inspection elements: Access Control

(1)

• Tier I: All requirements

• Tier II: 02.06 a-d, 02.07 a, 02.08 a-c

• Tier III: 02.10 a

71130.05 - Protective Strategy Evaluation

The inspectors evaluated the licensee's protective strategy through completion of the following

procedure elements: Protective Strategy Evaluation

(1)

• Tier I: All Requirements

• Tier II: 02.05 a, 02.06 a-I, 02.06 m-n, 02.07 a, 02.07 d-e

• Tier III: 02.09 a-b, 02.10 a, 02.11 a

71130.09 - Security Plan Changes

The inspectors evaluated the security plan changes through completion of the following

procedure elements: Review Security Plan Changes (IP Section 02.01)

(1) Since the last NRC inspection of this program area, Security Plan Revision(s) 14 to 15 were implemented based on your determination, in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 50.54(p)(2), that the changes resulted in no decrease in safeguards effectiveness of the security plan, and that the revised security plan changed continues to meet the requirements of 10 CFR 73.55(b). The inspectors conducted a review of the security plan changes to evaluate for potential decrease in safeguards effectiveness of the security plan. However, this review does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On October 22, 2020, the inspectors presented the security baseline inspection results to Mr. Frank Payne and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.02 Procedures NOBP-LP-1003 Unescorted Access In-Processing 11

NOBP-LP-1013 Safeguards Information Background Investigation 01

NOP-LP-1001 Unescorted Access Requirements 20

NOP-LP-1001 Unescorted Access Requirements 20

NOP-LP-1102 Protection of Safeguards Information 07

NOP-LP-1104 Security-Related Access Control Devices 05

NOP-LP-1202 Vehicle and Material Access Control 10

NOP-LP-1203 Security Badge Control 06

NOP-LP-1204 Primary Access Controls 10

NOP-LP-1205 Visitor Control to Protected and Vital Areas 06

Self-Assessments MS-C-18-10-19 Fleet Oversight Audit Report 0

SA-BN-2020- Analysis of Security Access Control Program in Relation to 0

1939 NRC Inspection Criteria Outlined in Inspection Guide

71130.02

71130.05 Calculations EESFEN-1608- Perry Nuclear Blast Security Calculation and Documentation 0

018; FEN003 Review

SPS-0532 Design of VBS Penetration at Perry Nuclear Power Plant for 11/06/2018

CALC50: 28.000 DBT

Miscellaneous Memorandum of Agreement Between Perry Nuclear Power 10/12/2019

Plant and Lake County Sheriff's Office

Perry Nuclear Power Plant Physical Security Plan 15

FELP #ADV Adversary Training 04

Procedures NOBP-LP-1114 Adversary Team Program 04

NOBP-LP-1207 Security/Adversary Timeline Guidance 01

NOP-LP-1003 Threat Reporting and Two Person Line of Sight Rule 05

NOP-LP-1107 Safety and Security Interface 04

NOP-LP-1402 Performance Evaluation Program 02

SPI-0006 Security Patrol and Alarm response Instruction 60

71130.09 Miscellaneous Perry Nuclear Power Plant Physical Security Plan 14

Select Security Drills & Exercise Packages from 2019-2020 01/01/2019 -

Evaluating Protective Strategy Changes 01/01/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

L-20-004 Perry Nuclear Power Plant Physical Security Plan Change 02/07/2020

50.54 (p) Submittal Letter & Attachments

6